How to build Principal Mining Hazard Management Plans using risk studies and bowtie analysis
Principal Mining Hazard Management Plans are a new fact of life for the mining sector, and they can take significant effort to develop. Here we’ll be looking at how you can leverage your existing corporate knowledge using the right tools to develop these kinds of documents.
The Australian mining and resources sector is the backbone of our economy: it is also a highly safety-conscious industry, and with good reason. A total of 49 workers died in Australia in 2016 in the natural resources sector (around 28% of all workplace fatalities).
As more state governments roll out the requirement for Principal Mining Hazard Management Plans, miners will face new scrutiny in how they manage their health and safety risks.
Principal Mining Hazards
The regulation of the mining sector is drawing on inspiration from the process safety domain. Businesses who work with highly dangerous substances have been required to meet strict compliance obligations for quite some time. Here we’re talking about businesses that manufacture, transport or store substances (such as anhydrous ammonia and natural gas, for example) above a certain threshold quantity.
These businesses have been required to submit safety cases and develop plans for principal hazards and major accident events. The upside of this is that miners have the benefits of the experience and tools developed by major hazard facility (MHF) operators over the past few decades.
The precise definition of what constitutes a principal mining hazard will depend on the legislation in each jurisdiction, although the intention is that there will be alignment with the National Mine Safety Framework.
In New South Wales, a principal hazard has “reasonable potential to result multiple deaths in a single incident or a series of recurring incidents”, with a particular list of hazard types to be considered (e.g. fire, inrush).
In the process safety space, these types of hazards are managed using hazard studies, layers of protection analysis and critical control verification. These form the core of the safety report (aka safety case) submitted to the regulator. The same approach could work well for miners looking to build their Principal Hazard Management Plans.
Hazard Studies – Principal Mining Hazards
Hazard studies are collaborative risk assessments that target a particular area of work. In process safety, these are typically HAZID (hazard identification) or HAZOP (hazard and operability study). Mining safety professionals might be more familiar with the HIRA (hazard identification and risk assessment) format.
The purpose of a hazard study is to identify, characterise and categorise the hazards in a particular area of work. That might be a particular plant, process or site. The focus is on what the hazards are and how they manifest. The object is to understand the hazards in an area of work. Hazard studies draw on the expertise and experience of the safety team: a hazard study should never need to be a blank slate exercise, because the existing expertise of the participants will drive the exercise.
Hazard studies are typically conducted with the aid of spreadsheets or specialised software. The output of a hazard study is a formatted report, with a dataset that can be used for further analysis. In RiskView, for example, the software outputs a study report in various formats. The data from the study can be used to generate more detailed hazard analysis.
This is why hazard studies are a logical building block for Principal Mining Hazard Management Plans. The plan needs to document the hazards that are present, how they manifest, and what the level of residual risk is. The report from a hazard study provides all this information, together with a summary of the participants who contributed to the risk assessment, and a summary of the research actions that went into the decision-making process.
Using RiskView, for example, the hazards are summarised in an editable report format. This can be adapted to suit a larger plan if desired. You can even import existing risk assessments into the hazard study in order to save time and leverage existing knowledge. RiskView provides a structure for the hazard study that encourages the user to think about causes, consequences, nodes and controls. The output is then a hazard study that is more robust and well thought-out.
The other advantage of this approach is that the data from the hazard study in RiskView can be used to automatically populate more advanced analysis: for example, bowtie risk assessment or layers of protection analysis. The causes, consequences, controls, and risk metrics for each principal mining hazard are automatically taken across into the bowtie diagram.
This means that the safety team can immediately move on to more detailed analysis of the principal hazard controls.
Layers of Protection Analysis and Critical Controls – Principal Hazard Controls
Not all the hazards identified in the hazard study will turn out to be principal mining hazards. Out of perhaps 50 or 100 hazards considered, there may only be a couple of dozen that meet the criteria. Those that make the cut need to be analysed and have principal hazard controls.
Principal hazard controls, which we might also call critical controls, make the most significant difference to reducing the risk associated with a principal mining hazard. They are the most important controls and require ongoing assurance.
Drawing again on the process safety example, critical controls are usually identified through bowtie risk assessments or layers or protection analysis. A tabular risk assessment does not work well for critical controls, because it is difficult to identify the critical controls along particular causal pathways of the hazard (for more on what critical controls are, see our critical control identification guide).
Often, the biggest hurdle to using bowties is the amount of effort involved in building the diagrams. If we keep using RiskView, we can actually eliminate this barrier by using the hazard study we developed earlier. We can select any number of principal mining hazards from the hazard study, and automatically generate a pre-populated bowtie diagram. Alternately, we can request a complimentary conversion of our existing bowtie diagrams from other software into RiskView.
Combined with the intuitive interface, this brings down the time taken to complete a bowtie from around 6-8 hours per diagram, to less than 1 hour. With a couple of dozen principal mining hazards coming out of a hazard study, that equates to one or two sessions to complete our detailed risk analysis.
Identifying critical controls is much simpler and more defensible using bowtie risk assessments. If we plot the effectiveness of every control on the diagram, the controls that make the biggest difference along each pathway are easily apparent (look for the change in line thickness).
Controls that appear along multiple pathways or across multiple bowties will also qualify for consideration as principal hazard controls.
RiskView can also be used to standardise how these principal hazard controls are used across the business. Once the controls are identified, they can be established as base controls within the system. They are given a common set of properties (such as effectiveness, position on the hierarchy of risk controls) which are then used whenever that control is used in a risk assessment.
This gives the safety team a more defensible position for their selection and use of principal hazard controls. The reasoning behind the selection of critical controls is easily justified using the bowtie diagrams (and also any research actions generated and closed out in the system during the study). The consistent application of the control across the entire Principal Mining Hazard Management Plan is easily demonstrated using the base controls panel.
The selection of principal hazard controls in RiskView also allows us to create assurance activities that directly link back to the critical control and the principal hazard(s) that it affects. This feeds into the ability to demonstrate ongoing compliance to the regulator.
Safety Cases, Safety Reports and Performance Reporting
The framework of regulatory submissions currently used in process safety is a good indication of what to expect in mine safety moving forward.
The business is required to submit a safety case (sometimes called a safety report) which demonstrates that the business has effective systems in place to reduce the risk of harm. In this case, the Principal Mining Hazard Management Plan is a core part of that submission.
There are also ongoing reporting obligations, which may be subject to formal review at the time. In process safety this is a quarterly or biannual schedule of performance reporting.
If we have built our Principal Mining Hazards, Principal Hazard Controls and Plan using a platform like RiskView, the reporting aspects are straightforward. Chemical manufacturers and other high-risk MHFs have been using RIskView for their safety case obligations for years without issue.
As we mentioned earlier, completed hazard studies can be exported as editable reports from RiskView. These can then form the backbone of the safety case or Principal Mining Hazard Management Plan.
The bowtie risk assessments and diagrams can also be exported and appended to the report. We then have a report which shows the summary of all hazards considered, the hazards selected as principal mining hazards, and detailed diagrams of the principal mining hazards. We also have the principal hazard controls clearly identified on each diagram, and potentially summarised as part of the report. RiskView has a range of report templates that can be used for this.
Performance reporting can be simplified and made less resource-intensive if we also use RiskView for this aspect of compliance. In essence, we can use RiskView for our safety case submissions and for everyday risk registers and audit activities. A number of MHF operators use RiskView for both their regulatory obligations and their everyday work (see one of our case studies for more).
Verification activities in RiskView can be targeted to particular principal mining hazards, principal hazard controls or major accident events. Each audit can be mapped to any combination of these, using performance standards that are created within the system.
In-field verification can use the RiskView mobile auditing tool, which captures audit findings in the field (with or without an internet connection). The data syncs back to the RiskView dashboard with immediate results shown.
When it comes time for performance reporting, the data can easily be extracted from RiskView. The process takes a few minutes, rather than spending a day or two manually formatting a report.
This provides the safety team with a robust way to handle their principal mining hazard obligations, whilst actually reducing the effort involved maintaining the overall mine safety management system.
The key is to leverage the existing knowledge of the safety team (and the corporate knowledge of the business as a whole) in new ways. Principal Mining Hazard Management Plans are a new approach for many miners, but they draw on existing practices and hard-won expertise.
It makes sense to use the right tools to make the most of existing knowledge.